https://www.taxtmi.com/caselaws?id=5271 SC held that the reassessment notice issued u/s 148, read with ss. 142(1) and 143(2), beyond four years from the end of the relevant assessment year, was invalid. It ruled that there was no failure by the assessee to fully and truly disclose all material (primary) facts, so s. 147(a) was inapplicable. Consequently, only s. 147(b) read with s. 149(1)(b) could govern, restricting issuance of notice to within four years. As the impugned notice was admittedly issued beyond this limitation, it was barred by time. Exercising jurisdiction under Art. 226, SC allowed the assessee's appeal, dismissed the Revenue's appeal, and quashed the notice u/s 148. en-us Fri, 10 Feb 1989 00:00:00 +0530 Wed, 03 Dec 2025 16:59:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=5271 SC held that the reassessment notice issued u/s 148, read with ss. 142(1) and 143(2), beyond four years from the end of the relevant assessment year, was invalid. It ruled that there was no failure by the assessee to fully and truly disclose all material (primary) facts, so s. 147(a) was inapplicable. Consequently, only s. 147(b) read with s. 149(1)(b) could govern, restricting issuance of notice to within four years. As the impugned notice was admittedly issued beyond this limitation, it was barred by time. Exercising jurisdiction under Art. 226, SC allowed the assessee's appeal, dismissed the Revenue's appeal, and quashed the notice u/s 148. Case-Laws Income Tax Fri, 10 Feb 1989 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=5271